Arizona Attorney General

Mark Brnovich



U.S. Supreme Court Upholds Arizona's Insanity Defense Law

(Phoenix, Ariz. – June 29, 2006) The United States Supreme Court today upheld the conviction of Eric Clark for the murder six years ago of Flagstaff Police Officer Jeff Moritz. By a 6-3 vote, the Court rejected Clark’s challenge of Arizona’s insanity defense and other restrictions in Arizona law regarding the use of mental illness evidence in criminal cases.

“I am pleased the Court recognized the authority of Arizona’s and other states’ Legislatures to establish the requirements for an insanity defense,” Arizona Attorney General Terry Goddard said. “This decision is a victory for states’ rights and for the victim’s family. It’s also a tribute to the fine work of Randall Howe, chief counsel of our Criminal Appeals Section, and Assistant Attorney General Michael O’Toole, who represented the state before the Supreme Court.”

The case marks the first major ruling by the U.S. Supreme Court on insanity defense laws since many states, including Arizona, made them more restrictive following John Hinckley’s acquittal by reason of insanity in the 1981 shooting of President Ronald Reagan. The Arizona Legislature stiffened its law in 1993.

On June 21, 2000, Clark shot and killed Moritz, a 30-year-old father. The shooting occurred after Moritz responded to a 911 call at 4:42 a.m. concerning a vehicle that was driving around the block in a residential neighborhood blaring loud music. Clark was subsequently convicted of first-degree murder for intentionally or knowingly causing the death of a police officer in the line of duty.

Both sides agreed that Clark, who was 17 at the time of the shooting, suffered from mental illness. The trial court, however, concluded that Clark was not legally insane because he knew that the act he committed was wrong. In addition, the trial court concluded the state had established beyond a reasonable doubt that Clark committed first-degree murder. Clark was sentenced to 25 years to life following his conviction. The Arizona Court of Appeals had affirmed Clark’s conviction.